Global Privacy Policy

PART A – GENERAL

1. About this Policy

This Part A (General) (the “Policy”) applies to the collection, holding, use, and disclosure (“processing”) of the personal data of individuals outside Japan by PERSOL CAREER CO., LTD. (“we,” “our,” or “us”).

2. How We Collect Your Personal Data

(a) For job seekers

Information you provide us. We may receive information that you provide to us, whether by email, in a letter, or otherwise, such as your name, address, email address, telephone number, workplace information, division and department, title, position, Curriculum Vitae (CV), recommendation, job history, and other information needed to apply for jobs or to introduce recruitment information, details of your inquiry, and other related information.

Information we obtain from other sources. We also may receive information from our affiliates and agents, such as your name, address, email address, telephone number, workplace information, division and department, title, position, Curriculum Vitae (CV), recommendation, job history, and other information needed to apply for jobs or to introduce recruitment information, details of your inquiry, and other related information.

(b) For hiring company personnel

Information you provide us. We may collect information that you provide to us, whether by email, in a letter, or otherwise, such as your name, email address, telephone number, fax number, workplace information, division and department, title, position, and other related information.

Information we obtain from other sources. We also may receive information from our affiliates and agents, such as your name, email address, telephone number, fax number, workplace information, division and department, title, position, and other related information.

3. Purposes of Processing Personal Data

We process the personal data that we hold about you for the purposes set forth below. We will process your personal data only to the extent necessary to fulfill the following purposes:

(a) For job seekers

(i) to address your request;
(ii) to provide services through our affiliates and agents or to provide services directly to you based on the request of our affiliates and agents;
(iii) to contact you (including to address your inquiry);
(iv) to request your cooperation in surveys related to our business activities for purposes of improvement and/or expansion;
(v) to conduct analysis, statistical processing and machine learning aimed at improving services we provide and developing other services;
(vi) to comply with any laws and regulations applicable to us;
(vii) to cooperate with relevant governmental authorities and agencies, including competent data protection authorities and those that are engaged in administrative or criminal investigations; and
(viii) to establish, exercise, or defend legal claims.

(b) For hiring company personnel

(i) to address your request or perform an agreement with you;
(ii) to provide services directly or through our affiliates and agents;
(iii) to contact you (including to address your inquiry);
(iv) to request your cooperation in surveys related to our business activities for purposes of improvement and/or expansion;
(v) to conduct analysis, statistical processing and machine learning aimed at improving services we provide and developing other services;
(vi) to comply with any laws and regulations applicable to us;
(vii) to cooperate with relevant governmental authorities and agencies, including competent data protection authorities and those that are engaged in administrative or criminal investigations; and
(viii) to establish, exercise, or defend legal claims.

4. Disclosure of Personal Data to Recipients and Joint Use of Personal Data

We may disclose your personal data to the following categories of recipients:

(a) Employees: We may disclose your personal data to our employees who have the authority and necessity to access the personal data.
(b) Service providers: We may disclose your personal data to service providers, such as IT service providers.
(c) Third parties: We may disclose your personal data to third parties, such as our affiliates, agents, job seekers (the personal data of hiring company personnel only) and hiring companies (the personal data of job seekers only).

We may otherwise disclose your personal data to any third party other than those set forth above, including public agencies, if such disclosure is required to achieve the purposes for which you provided personal data to us or other purposes that we specify when obtaining consent or personal data from you, to the extent necessary to comply with any laws and regulations applicable to us, to cooperate with relevant governmental authorities and agencies, or to establish, exercise or defend legal claims.

Under Japanese law, we may use the joint use framework under the Act on the Protection of Personal Information to share personal data on hiring company personnel referred to in Section 2 (How We Collect Your Personal Data) with PERSOL Group (the current list of Group companies can be seen at: https://www.persol-group.co.jp/en/corporate/group/), for the purposes of communication and offering services provided by PERSOL Group and relevant information, and for inquiring about preferences. The person in charge of the management of jointly used personal data is as follows:

Company name: PERSOL HOLDINGS CO., LTD.
Address: 2-1-1 Yoyogi, Shibuya-ku, Tokyo
Representative: Takao Wada, Representative Director, President and CEO

We require all of the recipients of your personal data to treat it as confidential and only process it in accordance with the strict requirements of applicable data protection laws, regulations, and other applicable legal safeguards specified in the Addendum for each jurisdiction.

5. Storage Period for Personal Data

We will retain your personal data that we collect for the period necessary to process such personal data. However, this does not apply if we are required by laws or regulations to retain your personal data for a longer period, in which case, we will retain it for the period required by laws or regulations.

6. Your Rights

You have a number of legal rights in relation to the personal data that we hold about you. These rights may vary depending on where you are located and which data protection laws apply to the relationship between you and us, but typically will include:

(a) right to obtain information regarding the processing of your personal data and to access the personal data that we hold about you;
(b) right to request that we rectify your personal data if it is inaccurate or incomplete;
(c) right to request that we erase your personal data in certain circumstances;
(d) right to request that we restrict our processing of your personal data in certain circumstances;
(e) right to object to our processing of your personal data;
(f) right to receive your personal data in a structured, commonly used, and machine-readable format and/or to request that we directly transmit such personal data to a recipient where doing so is technically feasible; and
(g) right to withdraw your consent to our processing of your personal data at any time.

You may exercise any of your rights by contacting us, using the information about us indicated below in Section 8 (Contacts). You also can lodge a complaint with the data protection authority in the relevant jurisdiction if you believe that any of your rights has been infringed by us and for any other reason specified in Part B (Jurisdictional Requirements).

7. Security Control Measures

We implement measures that are necessary and appropriate for processing your personal data and otherwise controlling the security of personal information, such as the establishment of basic policies and rules for appropriate processing of personal information, as well as organizational, personnel, physical, and technical security measures. In addition, we conduct appropriate supervision of contractors and employees that process personal data. When processing personal data in a foreign country, we take appropriate security control measures after understanding the legislation relating to the protection of personal data in the relevant foreign country.

If you wish to know more about our security control measures, please contact us using the contact information indicated below in Section 8 (Contacts).

8. Contacts

If you have any questions about this Policy, your rights, or any other matter relating to the protection of personal information, please contact us at the following email address:

Email address: globalcareer@persol.co.jp

The content of this Policy may be changed to protect your personal data or to comply with any amendment to laws, regulations, or other rules. You will be notified of any such changes on our websites, or by other means.

Effective Date: June 1, 2024